Mriehel photomontages not ‘naked eye’ as laid down in conditions

Photomontages submitted in the Environment Impact Statement for the Mriehel towers had to be a “faithful reproduction of what is visible to the naked eye”, according to the terms of reference for the project issued by the Planning Authority before the study was conducted in April 2015.  

Terms of reference are issued by the Environment and Resources Authority and its predecessor to highlight which studies are to be carried out in the EIS and also provide specific guidelines on how these studies are to be conducted.  

Most terms of reference issued in the past included a standard requirement that all photomontages should reflect “what is visible to the naked eye.” 

Photomontages showing the impact of the Mriehel high-rise on sensitive views like those from the Mdina bastions or Hastings Garden in Valletta were taken using a 25mm wide angle. 

Photographer Daniel Cilia contends that the photomontages had been taken with a wide-angle lens, which made objects appear more distant than they do to the human eye.  

Mriehel had been included as a high-rise zone by the government after the closure of the public consultation period

Cilia’s argument was supported by Environment and Resources Authority chairman Victor Axiak, who in a written submission said he had personally visited the Mdina viewpoint and found the actual view was different to that seen in the photographs.

The terms of reference for the Environment Impact Statement for the Mriehel towers specified that photomontages showing the impact of the towers on long distance views should be “of good quality, with faithful reproduction approximating as much as reasonably possible what would normally be visible to the naked eye.” 

A circular issued by the PA in November 2015, after the EIS was presented, specifies that when presenting photomontages showing the impact of particular projects on long distance views a “high quality digital SLR camera with a full frame sensor and a 50mm fixed focal length camera lens is used”. According to the circular the “use of a 28mm fixed focal length camera lens shall only be permitted in very particular circumstances”.